This chapter focuses on whether grantees can charge legal and lobbying expenses to the federal government. Boyar and Allen also cover how grantees should handle donated services and assets.

Objectives:

Judge which professional service costs are allowable under a federal award

Judge which legal costs are allowable under a federal award

Distinguish between lobbying costs and normal operating costs of a program

Determine how to treat services donated in support of a federal award

Professional Services Costs

The costs of professional and consultant services rendered by persons who are members of a profession, or possess a special skill and who are not officers or employees of the nonprofit or governmental unit, are generally allowable.

For instance, a not-for-profit may engage a tax accountant to prepare its tax return or might hire an engineer to look over its plans for a facility expansion.

The costs are allowable when reasonable in relation to the services rendered and when not contingent upon recovery of the costs from the federal government.

§200.459 Professional service costs.

(a) Costs of professional and consultant services rendered by persons who are members of a particular profession or possess a special skill, and who are not officers or employees of the non-Federal entity, are allowable, subject to paragraphs (b) and (c) when reasonable in relation to the services rendered and when not contingent upon recovery of the costs from the Federal government. In addition, legal and related services are limited under §200.435 Defense and prosecution of criminal and civil proceedings, claims, appeals and patent infringements.

The cost principles offer several factors to consider when determining the allowability of costs related to professional services, including:

The nature and scope of the service rendered,

The necessity of contracting for the service,

The past pattern of such costs,

The impact of federal awards on the governmental unit’s or nonprofit organization’s business,

Whether the service can be performed more economically by direct employment,

The qualifications of the individual, and

The adequacy of the contractual agreement for the services.

§200.459 Professional service costs.

(b) In determining the allowability of costs in a particular case, no single factor or any special combination of factors is necessarily determinative. However, the following factors are relevant:
(1) The nature and scope of the service rendered in relation to the service required.
(2) The necessity of contracting for the service, considering the non-Federal entity’s capability in the particular area.
(3) The past pattern of such costs, particularly in the years prior to Federal awards.
(4) The impact of Federal awards on the non-Federal entity’s business (i.e., what new problems have arisen).
(5) Whether the proportion of Federal work to the non-Federal entity’s total business is such as to influence the non-Federal entity in favor of incurring the cost, particularly where the services rendered are not of a continuing nature and have little relationship to work under Federal awards.
(6) Whether the service can be performed more economically by direct employment rather than contracting.
(7) The qualifications of the individual or concern rendering the service and the customary fees charged, especially on non-federally funded activities.
(8) Adequacy of the contractual agreement for the service (e.g., description of the service, estimate of time required, rate of compensation, and termination provisions).

In order to be allowable, retainer fees must be evidence of bona fide services available or rendered. Note that services do not necessarily have to be rendered, so long as they are available.

§200.459 Professional service costs.
(c) In addition to the factors in paragraph (b) of this section, to be allowable, retainer fees must be supported by evidence of bona fide services available or rendered.

Legal Defense Costs

Definitions Used for Legal Defense Costs

Paragraph (a) of §200.435 provides specific definitions of “conviction,” “costs,” “fraud,” “penalty,” and “proceeding” to be used for purposes of determining the allowability of costs related to legal defense and prosecution.

(a) Definitions for the purposes of this section.
(1) Conviction means a judgment or conviction of a criminal offense by any court of competent jurisdiction, whether entered upon verdict or a plea, including a conviction due to a plea of nolo contendere.
(2) Costs include the services of in-house or private counsel, accountants, consultants, or others engaged to assist the non-Federal entity before, during, and after commencement of a judicial or administrative proceeding, that bear a direct relationship to the proceeding.
(3) Fraud means:
(i) Acts of fraud or corruption or attempts to defraud the Federal government or to corrupt its agents,
(ii) Acts that constitute a cause for debarment or suspension (as specified in agency regulations), and
(iii) Acts which violate the False Claims Act (31 U.S.C. 3729-3732) or the Anti-kickback Act (41 U.S.C. 1320a-7b(b)).
(4) Penalty does not include restitution, reimbursement, or compensatory damages.
(5) Proceeding includes an investigation.
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Permissible Legal Defense Costs

In general, legal expenses[1] required in the administration of federal programs by non-Federal entities are allowable. However, the federal government does impose limitations on legal expenses involved with defense of civil or criminal charges.

Under the cost principles, legal costs are a little tricky, but not if you think about things from the federal government’s perspective. For instance, you can’t use federal grant monies to fight the federal government in court. Why would they hand you the stick with which to beat them?

Section 200.435 Defense and prosecution of criminal and civil proceedings, claims, appeals and patent infringements establishes the rules applicable to the recovery of legal costs related to grant administration. Because the rules are complex and obviously written by lawyers, we strongly recommend that, if the issue arises, you confer with legal counsel before deciding which costs would be permissible in any specific case. In general, to be able to claim the costs of a legal defense, the defendant needs to be exonerated. Any determination against the defendant, or a negotiated agreement, will normally render cost incurred as unallowable.

(b) Costs.
(1) Except as otherwise described herein, costs incurred in connection with any criminal, civil or administrative proceeding (including filing of a false certification) commenced by the Federal government, a state, local government, or foreign government, or joined by the Federal government (including a proceeding under the False Claims Act), against the non‑Federal entity, (or commenced by third parties or a current or former employee of the non-Federal entity who submits a whistleblower complaint of reprisal in accordance with 10 U.S.C. 2409 or 41 U.S.C. 4712), are not allowable if the proceeding:
(i) Relates to a violation of, or failure to comply with, a Federal, state, local or foreign statute, regulation or the terms and conditions of the Federal award, by the non-Federal entity (including its agents and employees); and
(ii) Results in any of the following dispositions:
(A) In a criminal proceeding, a conviction.
(B) In a civil or administrative proceeding involving an allegation of fraud or similar misconduct, a determination of non-Federal entity liability.
(C) In the case of any civil or administrative proceeding, the disallowance of costs or the imposition of a monetary penalty, or an order issued by the Federal awarding agency head or delegate to the non-Federal entity to take corrective action under 10 U.S.C. 2409 or 41 U.S.C. 4712.
(D) A final decision by an appropriate Federal official to debar or suspend the non‑Federal entity, to rescind or void a Federal award, or to terminate a Federal award for default by reason of a violation or failure to comply with a statute, regulation, or the terms and conditions of the Federal award.
(E) A disposition by consent or compromise, if the action could have resulted in any of the dispositions described in paragraphs (b)(1)(ii)(A) through (D) of this section.
(2) If more than one proceeding involves the same alleged misconduct, the costs of all such proceedings are unallowable if any results in one of the dispositions shown in paragraph (b) of this section.
(c) If a proceeding referred to in paragraph (b) of this section is commenced by the Federal government and is resolved by consent or compromise pursuant to an agreement by the non‑Federal entity and the Federal government, then the costs incurred may be allowed to the extent specifically provided in such agreement.
(d) If a proceeding referred to in paragraph (b) of this section is commenced by a state, local or foreign government, the authorized Federal official may allow the costs incurred if such authorized official determines that the costs were incurred as a result of:
(1) A specific term or condition of the Federal award, or
(2) Specific written direction of an authorized official of the Federal awarding agency.
(e) Costs incurred in connection with proceedings described in paragraph (b) of this section, which are not made unallowable by that subsection, may be allowed but only to the extent that:
(1) The costs are reasonable and necessary in relation to the administration of the Federal award and activities required to deal with the proceeding and the underlying cause of action;
(2) Payment of the reasonable, necessary, allocable and otherwise allowable costs incurred is not prohibited by any other provision(s) of the Federal award;
(3) The costs are not recovered from the Federal Government or a third party, either directly as a result of the proceeding or otherwise; and,
(4) An authorized Federal official must determine the percentage of costs allowed considering the complexity of litigation, generally accepted principles governing the award of legal fees in civil actions involving the United States, and such other factors as may be appropriate. Such percentage must not exceed 80 percent. However, if an agreement reached under paragraph (c) of this section has explicitly considered this 80 percent limitation and permitted a higher percentage, then the full amount of costs resulting from that agreement are allowable.
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(h) Costs of legal, accounting, and consultant services, and related costs, incurred in connection with patent infringement litigation, are unallowable unless otherwise provided for in the Federal award.
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(i) Costs which may be unallowable under this section, including directly associated costs, must be segregated and accounted for separately. During the pendency of any proceeding covered by paragraphs (b) and (f) of this section, the Federal government must generally withhold payment of such costs. However, if in its best interests, the Federal government may provide for conditional payment upon provision of adequate security, or other adequate assurance, and agreement to repay all unallowable costs, plus interest, if the costs are subsequently determined to be unallowable.

Unallowable Legal Costs

When a non-Federal entity incurs legal expenses to prosecute a claim against the federal government, the related costs are unallowable. Under 2 CFR 200, some legal costs are always unallowable:

Costs of legal, accounting, and consultant services, and related costs, incurred in connection with defense against federal claims or appeals, antitrust suits, or the prosecution of claims or appeals against the federal government;

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(f) Costs incurred by the non-Federal entity in connection with the defense of suits brought by its employees or ex-employees under section 2 of the Major Fraud Act of 1988 (18 U.S.C. 1031), including the cost of all relief necessary to make such employee whole, where the non‑Federal entity was found liable or settled, are unallowable.
(g) Costs of prosecution of claims against the Federal government, including appeals of final Federal agency decisions, are unallowable.
(h) Costs of legal, accounting, and consultant services, and related costs, incurred in connection with patent infringement litigation, are unallowable unless otherwise provided for in the Federal award.
(i) Costs which may be unallowable under this section, including directly associated costs, must be segregated and accounted for separately. During the pendency of any proceeding covered by paragraphs (b) and (f) of this section, the Federal government must generally withhold payment of such costs. However, if in its best interests, the Federal government may provide for conditional payment upon provision of adequate security, or other adequate assurance, and agreement to repay all unallowable costs, plus interest, if the costs are subsequently determined to be unallowable.

We should point out that all of these issues relate to costs incurred in criminal or civil proceedings. Researching data to refute an audit finding, for example, is perfectly acceptable, although we must remember that the general cost principles always apply. If the costs are unreasonable or unnecessary, they will be unallowable.

Lobbying Expenses

Lobbying Costs (Governmental Grantees)

Under the cost principles for governmental units, the costs of certain activities associated with obtaining grants, contracts, cooperative agreements, or loans are unallowable.

If a governmental unit incurs costs trying to implicitly or explicitly “improperly influence” an executive branch employee or officer for the purpose of considering or taking action on a “sponsored agreement or a regulatory matter,” then the costs are unallowable. What is meant by “improperly influencing” is not allowing the substance’s intrinsic value to be the basis of the decision, but instead using another means to persuade the employee or officer. The concern, of course, is with bribery, political pressure, and any other corrupting influence.

§200.450 Lobbying.
(a) The cost of certain influencing activities associated with obtaining grants, contracts, cooperative agreements, or loans is an unallowable cost. Lobbying with respect to certain grants, contracts, cooperative agreements, and loans is governed by relevant statutes, including among others, the provisions of 31 U.S.C. 1352, as well as the common rule, “New Restrictions on Lobbying” published at 55 FR 6736 (February 26, 1990), including definitions, and the Office of Management and Budget “Governmentwide Guidance for New Restrictions on Lobbying” and notices published at 54 FR 52306 (December 20, 1989), 55 FR 24540 (June 15, 1990), 57 FR 1772 (January 15, 1992), and 61 FR 1412 (January 19, 1996).
(b) Executive lobbying costs. Costs incurred in attempting to improperly influence either directly or indirectly, an employee or officer of the executive branch of the Federal government to give consideration or to act regarding a Federal award or a regulatory matter are unallowable. Improper influence means any influence that induces or tends to induce a Federal employee or officer to give consideration or to act regarding a Federal award or regulatory matter on any basis other than the merits of the matter.
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The lobbying rules for state and local governments are much less stringent than the rules for nonprofits. That is probably because state and local governments are political in their nature. We all expect that our governor, city supervisors, representatives, etc. will be trying to secure additional funding for their constituents.

Lobbying Costs (Non-Governmental Grantees)

Unallowable Lobbying Costs

Under the cost principles for nonprofit organizations, far more lobbying activities associated with obtaining grants, contracts, cooperative agreements, or loans are unallowable[2]:

Costs incurred in trying to implicitly or explicitly “improperly influence”[3] an executive branch employee or officer for the purpose of considering or taking action on a “sponsored agreement or a regulatory matter”;

Costs incurred in trying to influence, through in-kind or cash contributions, endorsements, or publicity, the outcomes of any federal, state, or local election, referendum, initiative, or similar procedure;

Costs incurred for the purpose of forming, running, contributing to, or paying the costs of a political party, campaign, political action committee (PAC), or other organization established with the intention of influencing the outcomes of elections;

Costs incurred to lobby or influence the introduction of federal or state legislation;

Costs incurred to influence the enactment or modification of any pending federal or state legislation; and

Costs for distributing or using publicity or propaganda, or urging members of the general public or any segment thereof to contribute to or participate in any mass demonstration, march, rally, fundraising drive, lobbying campaign or letter writing or telephone campaign.

§200.450 Lobbying.
(c) In addition to the above, the following restrictions are applicable to nonprofit organizations and IHEs:
(1) Costs associated with the following activities are unallowable:
(i) Attempts to influence the outcomes of any Federal, state, or local election, referendum, initiative, or similar procedure, through in-kind or cash contributions, endorsements, publicity, or similar activity;
(ii) Establishing, administering, contributing to, or paying the expenses of a political party, campaign, political action committee, or other organization established for the purpose of influencing the outcomes of elections in the United States;
(iii) Any attempt to influence:
(A) The introduction of Federal or state legislation;
(B) The enactment or modification of any pending Federal or state legislation through communication with any member or employee of the Congress or state legislature (including efforts to influence state or local officials to engage in similar lobbying activity);
(C) The enactment or modification of any pending Federal or state legislation by preparing, distributing, or using publicity or propaganda, or by urging members of the general public, or any segment thereof, to contribute to or participate in any mass demonstration, march, rally, fund raising drive, lobbying campaign or letter writing or telephone campaign; or
(D) Any government official or employee in connection with a decision to sign or veto enrolled legislation;
(iv) Legislative liaison activities, including attendance at legislative sessions or committee hearings, gathering information regarding legislation, and analyzing the effect of legislation, when such activities are carried on in support of or in knowing preparation for an effort to engage in unallowable lobbying.
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Permissible Lobbying Costs

Under the cost principles for nonprofit organizations, some costs related to influencing the decisions of federal and other officials of governmental units are allowable. Costs are allowable when grantees:

Present, in response to a documented appeal, technical and factual data on an issue directly related to a grant’s, contract’s or other agreement’s performance through hearing testimony, statements, or letters to the Congress or a state legislature, or subdivision, member, or cognizant staff member thereof;

Lobby or attempt to influence state legislation in order to directly reduce the cost, or to avoid material impairment of the organization’s authority to perform the grant, contract, or other agreement; or

Conduct an activity specifically authorized by law to be carried out using funds from the grant, contract, or other agreement.

§200.450 Lobbying.
(c)(2) The following activities are excepted from the coverage of paragraph (c)(1) of this section:
(i) Technical and factual presentations on topics directly related to the performance of a grant, contract, or other agreement (through hearing testimony, statements, or letters to the Congress or a state legislature, or subdivision, member, or cognizant staff member thereof), in response to a documented request (including a Congressional Record notice requesting testimony or statements for the record at a regularly scheduled hearing) made by the non-Federal entity’s member of congress, legislative body or a subdivision, or a cognizant staff member thereof, provided such information is readily obtainable and can be readily put in deliverable form, and further provided that costs under this section for travel, lodging or meals are unallowable unless incurred to offer testimony at a regularly scheduled Congressional hearing pursuant to a written request for such presentation made by the Chairman or Ranking Minority Member of the Committee or Subcommittee conducting such hearings;
(ii) Any lobbying made unallowable by paragraph (c)(1)(iii) of this section to influence state legislation in order to directly reduce the cost, or to avoid material impairment of the non-Federal entity’s authority to perform the grant, contract, or other agreement; or
(iii) Any activity specifically authorized by statute to be undertaken with funds from the Federal award.
(iv) Any activity excepted from the definitions of “lobbying” or “influencing legislation” by the Internal Revenue Code provisions that require nonprofit organizations to limit their participation in direct and “grass roots” lobbying activities in order to retain their charitable deduction status and avoid punitive excise taxes, I.R.C. §§501(c)(3), 501(h), 4911(a), including:
(A) Nonpartisan analysis, study, or research reports;
(B) Examinations and discussions of broad social, economic, and similar problems; and
(C) Information provided upon request by a legislator for technical advice and assistance, as defined by I.R.C. §4911(d)(2) and 26 CFR 56.4911-2(c)(1)-(c)(3).
(v) When a non-Federal entity seeks reimbursement for indirect (F&A) costs, total lobbying costs must be separately identified in the indirect (F&A) cost rate proposal, and thereafter treated as other unallowable activity costs in accordance with the procedures of §200.413 Direct costs.
(vi) The non-Federal entity must submit as part of its annual indirect (F&A) cost rate proposal a certification that the requirements and standards of this section have been complied with. (See also §200.415 Required certifications.)
(vii) (A) Time logs, calendars, or similar records are not required to be created for purposes of complying with the record keeping requirements in §200.302 Financial management with respect to lobbying costs during any particular calendar month when:
(1) The employee engages in lobbying (as defined in paragraphs (c)(1) and (c)(2) of this section) 25 percent or less of the employee’s compensated hours of employment during that calendar month; and
(2) Within the preceding five-year period, the non-Federal entity has not materially misstated allowable or unallowable costs of any nature, including legislative lobbying costs.
(B) When conditions in paragraph (c)(2)(vii)(A)(1) and (2) of this section are met, non‑Federal entities are not required to establish records to support the allowability of claimed costs in addition to records already required or maintained. Also, when conditions in paragraphs (c)(2)(vii)(A)(1) and (2) of this section are met, the absence of time logs, calendars, or similar records will not serve as a basis for disallowing costs by contesting estimates of lobbying time spent by employees during a calendar month.
(viii) The Federal awarding agency must establish procedures for resolving in advance, in consultation with OMB, any significant questions or disagreements concerning the interpretation or application of this section. Any such advance resolutions must be binding in any subsequent settlements, audits, or investigations with respect to that grant or contract for purposes of interpretation of this part, provided, however, that this must not be construed to prevent a contractor or non-Federal entity from contesting the lawfulness of such a determination.

Donated Services

Donated or volunteer services (professional and technical personnel, consultants, and other skilled and unskilled labor) are not reimbursable either as a direct or indirect cost. However, the value of donated services may be used to meet cost sharing or matching requirements in accordance with the provisions of the administrative rules.

If significant, the value of donated services should be considered in the determination of the governmental unit’s indirect costs or rate(s) and, accordingly, shall be allocated a proportionate share of applicable indirect costs. However, our experience indicates that this occurs very infrequently.

§200.434 Contributions and donations.
(a) Costs of contributions and donations, including cash, property, and services, from the non-Federal entity to other entities, are unallowable.
(b) The value of services … donated to the non-Federal entity may not be charged to the Federal award either as direct or indirect (F&A) cost. The value of donated services … may be used to meet cost sharing or matching requirements (see §200.306 Cost sharing or matching)….
(c) Services donated or volunteered to the non-Federal entity may be furnished to a non‑Federal entity by professional and technical personnel, consultants, and other skilled and unskilled labor. The value of these services is not allowable either as a direct or indirect cost. However, the value of donated services may be used to meet cost sharing or matching requirements in accordance with the provisions of §200.306 Cost sharing or matching.
(d) To the extent feasible, services donated to the non-Federal entity will be supported by the same methods used to support the allocability of regular personnel services.
(e) The following provisions apply to nonprofit organizations. The value of services donated to the nonprofit organization utilized in the performance of a direct cost activity must be considered in the determination of the non-Federal entity’s indirect cost rate(s) and, accordingly, must be allocated a proportionate share of applicable indirect costs when the following circumstances exist:
(1) The aggregate value of the services is material;
(2) The services are supported by a significant amount of the indirect costs incurred by the non-Federal entity;
(i) In those instances where there is no basis for determining the fair market value of the services rendered, the non-Federal entity and the cognizant agency for indirect costs must negotiate an appropriate allocation of indirect cost to the services.
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(f) Fair market value of donated services must be computed as described in §200.306 Cost sharing or matching.
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The following addresses the treatment of the indirect costs related to donated services:

§200.434 Contributions and donations.
(e)(2)(ii) Where donated services directly benefit a project supported by the Federal award, the indirect costs allocated to the services will be considered as a part of the total costs of the project. Such indirect costs may be reimbursed under the Federal award or used to meet cost sharing or matching requirements.
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Donated Property

Like donated services, the value of property contributed to a grant program cannot be claimed as either direct costs or indirect costs. However, it can be claimed as cost sharing. Generally, the amount that can be claimed as cost sharing is the fair market value of the items at the time of the contribution. However, the new rules contain a limitation on value that had not existed previously.

(g) Personal Property and Use of Space.
(1) Donated personal property and use of space may be furnished to a non-Federal entity. The value of the personal property and space is not reimbursable either as a direct or indirect cost.
(2) The value of the donations may be used to meet cost sharing or matching share requirements under the conditions described in §§200.300 Statutory and national policy requirements through 200.309 Period of performance of subpart D of this part. The value of the donations must be determined in accordance with §§200.300 Statutory and national policy requirements through 200.309 Period of performance. Where donations are treated as indirect costs, indirect cost rates will separate the value of the donations so that reimbursement will not be made.

For contributions of buildings or land, the value of the property for cost sharing purposes is the lesser of:

The book value in the contributor’s accounting records at the time of the donation; or

The fair market value of the item at the time of donation.

Because most real property has significantly increased in value over the years, any real property that is contributed to meet cost sharing requirements might be valued at far less than the current fair market value. My house would constitute a graphic example. My wife and I purchased it over 40 years ago. Its current market value is close to 20 times what I paid for it all those decades ago. However, its book value would be almost zero. It would be considered almost fully depreciated, so the book value would be miniscule.

The rules do permit the federal agency, with sufficient justification, to use the fair market value at the time of donation even if that value exceeds book value. This text is being written before the new rules become effective, so we do not know at this point how the federal agencies will handle such contributions. Although, if they do limit the amount of cost sharing to book value, real property contributions may decline substantially.

The regulations make it clear that if the contributed real property is not to be used as cost sharing, but rather is included in general inventory and depreciated, then this limitation will not apply. In such a case, the value would be the fair market value at the time of donation.

§200.306 Cost sharing or matching
(d) Values for non-Federal entity contributions of services and property must be established in accordance with §200.434 Contributions and donations. If a Federal awarding agency authorizes the non-Federal entity to donate buildings or land for construction/ facilities acquisition projects or long-term use, the value of the donated property for cost sharing or matching must be the lesser of paragraphs (d)(1) or (2) of this section.
(1) The value of the remaining life of the property recorded in the non-Federal entity’s accounting records at the time of donation.
(2) The current fair market value. However, when there is sufficient justification, the Federal awarding agency may approve the use of the current fair market value of the donated property, even if it exceeds the value described in (1) above at the time of donation.
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Chapter 6 Summary

Grantee organizations may require services that are not available within the organization itself. Thus, the costs of professional services are generally permissible. The costs are allowable when reasonable in relation to the services rendered and when not contingent upon recovery of the costs from the federal government.

In general, legal expenses required in the administration of federal programs are permissible. However, legal expenses for prosecution of claims against the federal government are unallowable. Legal expenses involving the defense of criminal or civil prosecution are unallowable when a proceeding is settled by consent or compromise, unless specifically provided for in the settlement agreement.

Lobbying costs incurred by either a governmental unit or nonprofit in an attempt to improperly influence an employee or officer of the executive branch of the federal government are unallowable. Under the cost principles for nonprofit organizations, far more lobbying activities associated with obtaining grants, contracts, cooperative agreements, or loans are unallowable. In addition to the above restriction, costs for the following activities are unallowable:

Attempting to influence the outcomes of election, referendum, initiative, or similar procedure;

Establishing, administering, contributing to, or paying the expenses of a political party, campaign, or political action committee;

Lobbying or influencing the introduction of federal or state legislation; and

Influencing the enactment or modification of any pending federal or state legislation.

Under the cost principles for nonprofit organizations, costs are allowable to:

Provide a technical and factual presentation of information on a topic directly related to the performance of an award;

Lobby or attempt to influence state legislation in order to directly reduce the cost, or to avoid material impairment of the organization’s authority to perform the grant, contract, or other agreement; or

Conduct an activity specifically authorized by statute to be undertaken with funds from the grant, contract, or other agreement.

Donated goods or services may not be claimed as either direct costs or indirect costs. However, they may be allowable as cost sharing or matching requirements in accordance with the provisions of the administrative rules.

[2] When an organization seeks reimbursement for indirect costs, total lobbying costs shall be separately identified in the indirect cost rate proposal, and thereafter treated as other unallowable activity costs.

[3] Improper influence is defined the same for both governmental units and nonprofit organizations.

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